Squillantini v. Republic
REITERATIONFacts
The Antecedents: Jose Clevio Manlio Squillantini, of Italian parentage, was born in Manila on June 29, 1923. He was taken to Italy at 14 months of age in 1924 and returned to the Philippines in 1926, continuously residing with his parents in Cebu. From August 1947, he resided in Bacolod, Negros Occidental, serving as manager of the Goodyear Tire & Rubber Company branch with a monthly salary of P450 plus a small commission. Procedural History: On December 3, 1947, Squillantini filed his application for naturalization. During the hearing on December 8, 1948, it was revealed that the applicant had resided in Negros Occidental for over a year from the date of the hearing, but only for approximately five months from the date of filing his application. The Court of First Instance decreed the naturalization of the applicant. The Petition: The Solicitor General appealed the decision, alleging that the lower court had not acquired jurisdiction over the case.
Issue(s)
Whether the Court of First Instance of Negros Occidental acquired jurisdiction over the naturalization petition when the applicant had only resided in the province for five months at the time of filing, notwithstanding that he had completed one year of residence by the time of the hearing.
Ruling
The Court reversed the decision of the Court of First Instance, dismissing the application for naturalization. The Court held that the lower court did not acquire jurisdiction over the case.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Court of First Instance (CFI) of Negros Occidental did not acquire jurisdiction over the case because the petitioner failed to satisfy the mandatory one-year residence requirement under Section 8 of Commonwealth Act (CA) No. 473. The law provides that the court of the province where the applicant has been domiciled for at least one year immediately preceding the filing of his application shall have original and exclusive jurisdiction. The Court clarified that this one-year period must be calculated from the date of the filing of the application, not from the date of the hearing or trial. Since the applicant had only resided in Negros Occidental for five months when the petition was filed on December 3, 1947, the jurisdictional requirement was not met. The Court emphasized that jurisdiction (competencia) is conferred by law and cannot be granted by the will of the applicant, the acquiescence of the fiscal, or the leniency of the presiding judge. Citing the principles in United States v. De la Santa and United States v. De la Cruz, the Court reiterated that when a legal requirement for the initiation of a case is absent, the court fails to acquire the power to validly adjudicate the matter. Consequently, the proceedings were void for lack of jurisdiction.
Main Doctrine
The Court of First Instance does not acquire jurisdiction over a naturalization case if the applicant has not resided in the province where the application is filed for at least one year immediately preceding the filing of the application, as required by Section 8 of the Revised Naturalization Law.